United States District Court, D. Nevada
L. VALLADARES Federal Public Defender
MONIQUE KIRTLEY Assistant Federal Public Defender
W. MYHRE Acting United States Attorney
MACFADDEN Assistant United States Attorney
STIPULATION TO CONTINUE OBJECTIONS TO REPORT AND
RECOMMENDATION [ECF NO. 82] (SECOND REQUEST)
L. VALLADARES, UNITED STATES DISTRICT JUDGE.
HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre,
Acting United States Attorney, and Kilby Macfadden, Assistant
United States Attorney, counsel for the United Stated of
America, and Rene L. Valladares, Federal Public Defender, and
Monique Kirtley, Assistant Federal Public Defender, counsel
for Virab Torosyan, that the Objections to Magistrate's
Report and Recommendation (ECF No. 82) be extended fourteen
(14) days, from the presently set date of August 17, 2017.
Stipulation is entered into for the following reasons:
1. On June 20, 2017, the Magistrate Court held a Motion
Hearing regarding defendant's Motion to Suppress (ECF No.
76). The Magistrate Court filed its Report and Recommendation
on July 28, 2017. (ECF. No. 82).
2. On August 8, 2017, Defense counsel ordered the transcript
from the Motion to Suppress Hearing. Defense counsel received
the transcript on August 17, 2017. Defense counsel needs time
to finish her objections to the Report and Recommendation
(ECF No. 82).
3. The defendant is incarcerated and does not object to the
4. The parties agree to the continuance.
5. The additional time requested herein is not sought for
purposes of delay, but merely to allow counsel for the
defendant sufficient time review the transcript of the Motion
Hearing and to file written objections to the Report and
6. Additionally, denial of this request for continuance could
result in a miscarriage of justice. The additional time
requested by this stipulation is excludable in computing the
time within which the trial herein must commence pursuant to
the Speedy Trial Act, § 3161(h)(7)(A), considering the